- 1 - HC-KAR NC: 2026:KHC:27445 WP No. 16330 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 16330 OF 2026 (T-IT) BETWEEN: SJR ENTERPRISES LIMITED CORPORATE SJR CYBER, SITE NO 22, LASKAR HOSUR MAIN ROAD, ADUGODI, BANGALORE-560030 (MR. J. VIJAY REDDY, AGED ABOUT 51 YEARS S/O MR. S. JAYARAM REDDY) REGISTERED UNDER COMPANIES ACT 1956. …PETITIONER (BY SRI.NARENDRA KUMAR J JAIN., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 6(1)(1) BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU-560027. 2. THE INCOME TAX OFFICER NATIONAL FACELESS ASSESSMENT CENTRE CENTRAL BOARD OF DIRECT TAXES Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:27445 WP No. 16330 of 2026 INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWARHARLAL NEHRU STADIUM, DELHI-110003. 3. THE ASSISTANT DIRECTOR OF INCOME TAX CENTRAL PROCESSING UNIT, (CPC) INCOME TAX DEPARTMENT BENGALURU-560500. 4. THE COMMISSIONER OF INCOME TAX APPEALS NATIONAL FACELESS ASSESSMENT CENTRE CENTRAL BOARD OF DIRECT TAXES INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWARHARLAL NEHRU STADIUM, DELHI-110003. …RESPONDENTS (BY SRI.Y.V. RAVIRAJ., ADVOCATE A/W SRI. VINAYAKA G PANDIT., ADVCATE FOR R1, R2 AND R4; SRI. ARAVIND V CHAVAN., ADVOCATE A/W SRI. NIRMAL MATHEW., ADVOCATE FOR R3) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A. ISSUE AS FAR AS PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF MANDAMUS OR OTHERWISE, TO THE LEARNED FIRST - 3 - HC-KAR NC: 2026:KHC:27445 WP No. 16330 of 2026 RESPONDENT TO GRANT REFUND OF AMOUNT SET- OFF IN EXCESS OF 20 PERCENT OF DEMAND FOR AY 2018-19 AS PER LETTER DATED 21.05.2026 ENCLOSED AS ANNEXURE G; B. ISSUE AS FAR AS PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF MANDAMUS OR OTHERWISE, DIRECTING THE LEARNED RESPONDENT TO GRANT INTEREST ON REFUND AS STIPULATED UNDER SECTION 244A FOR AY 2018-19 FROM THE DATE OF SUCH ADJUSTMENT TILL THE DATE OF ACTUAL REFUND; C. ISSUE AS FAR AS PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF MANDAMUS OR OTHERWISE, DIRECT THE LEARNED FOURTH RESPONDENT TO DISPOSE THE APPEAL AS PER ANNEXURE B EXPEDITIOUSLY AFTER PROVIDING AN OPPORTUNITY OF HEARING TO THE PETITIONER. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 4 - HC-KAR NC: 2026:KHC:27445 WP No. 16330 of 2026 CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The petitioner has filed this petition for consideration of the Representation dated 21.05.2026 [Annexure-G]. The petitioner's Representation relates to a request for a refund of the amount adjusted in excess of 20% of the demand. Sri Narendra Kumar J Jain, the learned counsel for the petitioner, relies upon the Orders of this Court dated 11.09.2025 in the writ petition in W.P. No. 17212/2025 to contend that the petitioner is entitled to refund of the amount set off in excess of 20% of the Demand. When queried, Sri Y V Raviraj and Sri Vinayaka G Pandit, the learned counsels for the first, second and fourth respondents, submit that the representation will be considered in the light of this Court’s order in the aforesaid writ petition. Hence the following: - 5 - HC-KAR NC: 2026:KHC:27445 WP No. 16330 of 2026 ORDER [a] The writ petition stands disposed of calling upon the respondents to decide on the petitioner's representation in the backdrop of this Court's order in the writ petition in W.P. No.17212/2025 and communicate the decision to the petitioner within four [4] weeks from the date of receipt of a certified copy of this order. [b] The petitioner is reserved with liberty to file a certified copy of this order with the respondents within a week from the date of receipt thereof. Sd/- (B M SHYAM PRASAD) JUDGE AN/-